Cameranesi v. U.S. Dep't of Defense, No. 14-16432 (9th Cir. 2016)
Annotate this CasePlaintiffs are two members of the School of the Americas Watch (SOAW), a human rights and advocacy group dedicated to monitoring the United States Army School of the Americas (SOA) graduates and lobbying for closure of the school. At issue in this appeal is whether the names of foreign students and instructors at the Western Hemisphere Institute for Security Cooperation (WHINSEC) are exempt from disclosure under Exemption 6 of the Freedom of Information Act (FOIA), 5 U.S.C. 552(b)(6). The court reversed the district court’s grant of summary judgment to plaintiffs, concluding that the disclosure of these names would constitute a clearly unwarranted invasion of personal privacy.
Court Description: Freedom of Information Act. The panel reversed the district court’s summary judgment in favor of plaintiffs, who brought an action under the Freedom of Information Act (“FOIA”) against the United States Department of Defense seeking the names of foreign students and instructors at the Western Hemisphere Institute for Security Cooperation. The panel held that the disclosure of the names of the foreign students and instructors would constitute a clearly unwarranted invasion of personal privacy, and was exempt from disclosure under Exemption 6 of FOIA. The panel held that the evidence submitted by the Department of Defense demonstrated that disclosure of the identities of the foreign students and instructors could give rise to harassment, stigma, or violence as a result of their association with the United States – exactly the sort of risks that courts have recognized as nontrivial. Judge Watford dissented, and he would affirm the district court’s summary judgment, because in his view the Department of Defense did not carry its burden of demonstrating that the students’ and instructors’ privacy interests outweighed the strong public interest in disclosures of their names. CAMERANESI V. U.S. DEP’T OF DEFENSE 3
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